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MANAGING RADIOACTIVE WASTE SAFELY

Annex 2

Consultation Questions and Briefing Sheets

Consultation Questions

1. Views are invited on the principle of segregating UK waste types by half-lives.

2. Views are invited on RWMAC's proposals for the management of spent sealed sources: the ring-fencing of additional resources for the management of historic redundant registered sources for which there is no current budget; requiring arrangements to be put in place such that all sales of new sources include provision for future disposal; and setting up a dedicated organisation with responsibility for taking abandoned sources under control.

3. Views are invited on the link between waste substitution and the availability of a long-term management strategy.

4. Views are invited on the general approach for decommissioning.

5. Views are invited on the policy to be adopted for the long-term management of UK separated plutonium, including whether some should be considered as waste.

6. Views are invited on the policy to be adopted for the long-term management of UK uranium stocks, including whether some should be considered as waste.

7. Views are invited on the suitability of these or any other consultation techniques for engaging the public in the radioactive management debate.

8. Views are invited on how the Government and the Devolved Administrations could build on these existing initiatives or develop any of the other techniques for engaging the public.

9. Your views are invited on the practicalities of this approach or alternative arrangement for funding the work.

10. Your views are invited on the need for an independent body to advise the government and the Devolved Administrations on information needs and research requirements ' and whether any of the organisations or models above would be able to provide the independent and authoritative advice and/or the research management we require. You are also invited, if you wish, to outline alternative arrangements for discharging these roles.

11. Your views are invited on this, and on which type of organisation could take on this co-ordination role.

12. Your views are invited on this indicative programme of action.

13. Views are invited on the whether the Environment Agency in England and Wales, and the Scottish Environment Protection Agency on Scotland require a new statutory power over the storage of wastes on nuclear licensed sites.

Radioactive Waste

• Waste contaminated by, or incorporating radioactivity above threshold levels defined in legislation, is known as radioactive waste
• Radioactivity is the spontaneous disintegration of unstable atomic nuclei in a process known as radioactive decay.
• The half-life is the time taken for half of any amount of atomic nuclei to decay. The half-life is unique and unchangeable.
• Some of the radioactive waste which needs to be managed in the UK contains atomic nuclei with half-lives of hundreds of thousands of years, and therefore needs to be segregated from the environment and human contact during the lifetimes of many generations to come.

The treatment and handling of radioactive wastes has been determined by the actual characteristics of the waste. However, for management purposes, rather than for any regulatory need, radioactive waste is divided into 4 categories according to its how much heat it generates and the activity content.

Classification

• The classification systems for radioactive waste in use across the European Union vary widely in approach and application. Some are used purely for communication purposes, while most are based on how types of waste are managed or by activity concentration.
• An EU Classification system has been proposed (to be used as well as National systems, not replace them). It is to be used to provide information to the Commission for the compilation of a European waste inventory.
• The main difference from the UK classification is the addition of categories for transitional waste that will decay within a short period of storage to unrestricted clearance levels, and the division of our ILW and LLW classifications into short-lived and long-lived LILW (Low and Intermediate Level Waste).
• This system would have the advantage of making it easier to identify appropriate ways of managing waste. However most UK wastes contain a mixture of atomic nuclei of different half-lives, which presents problems in operating such a system.
• Also the dose resulting from contact is not related to their half-life. The toxicity of similar half-lives is not necessarily the same.
• Therefore, the management of wastes is determined by the actual characteristics of the waste rather than by its classification.

This needs arrangements for all sales of new sources to include provision for future disposal and the setting up of a dedicated organisation with responsibility for taking abandoned sources under control.

Users

Nuclear Power Sector

• The large majority of the radioactivity in the UK's radioactive waste comes from the nuclear power sector.

Defence

• Defence wastes are those wastes that have been generated by Ministry of Defence (MOD) service and civilian establishments or companies that have undertaken work on behalf of the Ministry of Defence.

Small Users

• A 'small user' is the term given to organisations that produce radioactive wastes, but do not have sites licensed under the Nuclear Installations Act 1965. Small users include hospitals, universities, research laboratories, the offshore oil and gas industry and some non-nuclear industries. There are approximately 5,600 small users on civil unlicensed sites in England and Wales, about 900 in Scotland and 150 in Northern Ireland.

Spent Sealed Sources

• A 'sealed source' is a device in which a radioactive material has been contained within an outer casing. This outer casing makes an accidental release of the contents extremely unlikely.
• Sealed sources have an extensive range of medical, educational and industrial uses, notably in general diagnosis and cancer treatments, and in the oil and gas industries.
• Some spent sealed sources can be recycled into new sources by specialist source manufacturers, reusing the radioactivity contained in them. Others are simply wastes, for which a management route must eventually be found.
• As the UK currently has no final management route for ILW, special arrangements entailing considerable cost are required for the long-term storage of these sources at dedicated sites.
• Redundant sources are therefore frequently retained on small user premises. In addition to their own spent sources, small user organisations may also take control of sources that are found in the public domain (either as a result of accident, loss or abandonment) on a voluntary basis.
• Small users face serious difficulties, primarily financial, in dealing with spent sources.
• The Radioactive Waste Management Advisory Committee view is that the Government should consider the case for ring-fencing additional resources in order that the health and university sectors can make effective arrangements for the management of historic redundant registered sources for which there is no current budget. All sales of new sources should also include provision for future disposal. RWMAC also considers that for the UK a dedicated organisation could be given responsibility for taking abandoned sources under control.

Waste substitution

• Waste substitution is a means of changing the proportion of wastes through reprocessing, held in different categories and so the management of some contaminated materials.
• New reprocessing contracts for overseas customers signed since 1976 have included returning the resulting wastes back to the country of origin. However, waste substitution would reduce significantly the volume of wastes to be returned, and so the number of waste shipments to overseas customers through waste substitution.
• Current policy is that HLW arising from reprocessing should be returned to the country of origin as soon as possible. Waste substitution is allowed for LLW, where a disposal route exists.
• Substitution of HLW for ILW is dependent on the construction of a repository for intermediate level wastes - or some other kind of waste management facility if it is decided that disposal is not the right solution.
• Waste substitution would decrease the level of waste shipments around the world. It would also result in a decrease in the volumes of HLW to be managed in the UK, and an increase in the volumes of ILW.
• These wastes are only a small fraction of the volume of wastes of domestic origin and their retention should not create any new problems.
• They should not increase the amount of radioactivity, since the radioactive content of the additional wastes to be returned would be no less than that in the wastes remaining in the UK.
• Any approach to substitution needs to recognise principle of self-sufficiency in radioactive waste.
• No steps should be taken that would discourage other countries from providing their own waste facilities or which would create a waste management problem in the UK or create detriment.

Decommissioning

Dismantling a closed down nuclear facility and removal of its contents, both radioactive and non-radioactive, is known as decommissioning. Nuclear facilities include power stations, stores, and chemical plant and research facilities. The key objective in decommissioning a nuclear facility is to remove the hazard, safely.

Issues to be considered

There are many issues to be considered when decommissioning a nuclear facility. They include the type of facility (e.g. power station, chemical plant), its age, the condition of buildings and equipment, the level of radioactivity, the atomic nuclei involved and their concentration, or dispersal, around the facility, and many others.

• Decommissioning should be carried out without risks to people's safety and health.
• Early decommissioning has a number of advantages. For example, removing a large structure, often in an isolated and rural area, avoiding leaving problems for future generations, making good use of the expertise available among the staff and optimising the amount of site material available for reuse at the facility or elsewhere, or for recycling.
• Early decommissioning could produce considerably more radioactive waste (2 to 4 times as much intermediate level waste).
• Delaying decommissioning might benefit from the development of new technologies, though this should not be relied upon.
• In the case of reactors, early removal of radioactive material from the reactor (to be stored in waste containers) could increase the risk of radioactivity leakage.
• Dismantling of non-radioactive structures, or equipment, is normally carried out manually. The longer the facility has been closed down before decommissioning, the greater the opportunity for manual intervention.
• Remote techniques (robotics) for these operations exist and are being further developed. Use of robotics would enable decommissioning to start immediately after close down. Such techniques may prove to be slower, less resource efficient and more expensive. However, they could allow an earlier start to decommissioning and offer safety benefits.
• Completely decommissioning a facility immediately after close down would result in higher costs because of the more complex techniques and because of the larger volume of higher level waste produced.
• Costs are likely to increase from any delay in decommissioning beyond a few years because of the need to maintain the facility in a safe and secure condition.
• The UK currently has no intermediate level waste disposal facilities. There is, therefore, no scope for making savings in this area by early decommissioning.
• The cost of storing intermediate level waste until a long term solution has been found, would probably be greater than the alternative which would be to leave the facility in situ in a safe and secure condition.
• The likelihood of new innovations being developed is an important consideration. In drawing up a strategy it is important to recognise that during actual decommissioning new and improved technologies and techniques will become available.
• For this reason it is important that the strategies are reviewed regularly, and revised as appropriate so as to maximise the benefits arising from new technical developments.

Following these principles should allow robust and effective decommissioning. It is proposed that decommissioning strategies should continue to be prepared on a facility by facility basis. Strategies should be living documents and reviewed for their adequacy every 5 years. For nuclear reactors, the statutory consultations also need to be built in. The timetable for decommissioning should be determined by the licensee, in conjunction with the Health and Safety Executive. It should take into account all relevant factors including the type of facility, the nature of its radioactive inventory, the techniques needed to ensure worker safety and to protect the public and the environment, the costs of various options, and overall financial, economic and national resource issues.

Plutonium

• Plutonium is not currently classified as waste. On 31 December 2000, there were 61.5 tonnes of UK civil separated plutonium in the UK. The Government is committed to ensure that holdings of plutonium are managed safely and effectively in accordance with its international commitments on non-proliferation and in ways that ensure the protection of workers, the public and the environment. The Government's policy is designed to prevent the risk of the material being stolen or diverted for misuse. Plutonium can be used as a component in certain reactors such as Sizewell B or in other more advanced reactor designs.
• The longer separated plutonium remains in storage the less useful as reactor fuel as time progresses which is important in its potential use for power production.
• The House of Lords Select Committee on Science and Technology recommended that a strategic stock of plutonium should be retained in case it was required to fuel fast reactors in the future. They suggested that the remainder of existing stocks be declared as a waste. The Royal Society has also called for the disposal of some plutonium as waste.
• If plutonium, unsuitable for fuel, were categorised as waste it would be included in the UK's Radioactive Waste Inventory. There would also be a requirement that financial provisions should be made, such that if the option to re-use were not taken, the material could be treated in readiness for its long-term management.
• If some plutonium were classified as a waste, the combined stocks would, for the present, continue to be stored at Sellafield.
• In view of the large stock of plutonium existing in the UK, the fact that a fraction of it is currently unusable as fuel and the lack of UK reactor capacity to accept such fuel, it is important to consider whether some of the plutonium should now be classified as waste.

Uranium

• Uranium is not currently classified as waste.
• Reprocessed uranium can be, and has been, used to manufacture new fuel. However, it is currently uneconomic to use for this purpose due to the low cost of fresh uranium and the material is kept in storage.
• The measures which could be taken to address the issue of stocks of both reprocessed and depleted uranium are similar to those for plutonium.
• To avoid foreclosing any options for the future the materials could be retained in their current forms in safe secure storage, keeping it as a potential fuel should an increase in the cost of fresh uranium make its future use economic.
• Reprocessed uranium stored as drummed uranium oxide is already regarded as passively safe and depleted uranium hexafluoride could be treated to put it in a similar passive form for long-term storage pending a decision on future options. While this could be achieved without foreclosing the option of future use, the costs would be significant.
• If it were decided that the uranium is not going to be used in the future it would be put it in a form where it is unavailable for use. This would foreclose any future possibility of extracting the energy contained within it and require that in addition to the treatment costs, significant financial should be made available for its long-term management.
• In view of the large stock of uranium existing in the UK, the question arises whether this material should be retained for possible re-use in the future or if some should be considered as a waste.

Involving people

• There is a desire to provide more opportunities for public participation in environmental decision-making.
• There should be the widest opportunity for participation by people throughout society, without over-simplifying complex issues.
• To achieve this, we need to use a variety of methods for public participation sensitive to people with differing levels of knowledge and experience.

Techniques for Engaging the Public

Workshops
Interactive Panels
Community Advisory Committees
Citizens Juries Opinion Polls
Consensus Conference
Stakeholder Dialogue
Local Agenda 21 Groups
Public Meetings
Public hearings and inquiries
Open Houses
Research Panels
Internet
Community Council Consultations

Information Needs

• Whichever methods are chosen to involve the public the process will only work if the information given is accepted as accurate, objective and complete by all interested parties.

• It is suggested that an independent body be appointed to advise on what that information is, where further information is needed, and when enough information has been gathered for decisions to be taken.
• This body would need to have the experience and knowledge to give its views widespread respect, and sufficient independence from Government and the waste producers for its deliberations to be considered objective.

• The Government and the Devolved Administrations currently have available the Radioactive Waste Management Advisory Committee (RWMAC).

• It may be that RWMAC would need to be modified to perform the role envisaged, although new alternatives are not ruled out.
• If a new advisory body is set up, any further research, which is required, might be co-ordinated by another organisation acting as a centre for research expertise on radioactive waste management issues.

• While this organisation would also need to demonstrate its authority and independence, to be consistent with the polluter pays principle, its work should be financed by the waste producers, public and private.

• A further option would be to combine the advisory and research roles. This would provide a more integrated approach to advance of the knowledge required to develop policy.
• There are a number of organisations in existence, or which could be created, that would be able to fulfil one or both of these roles.

Information and Advice

• When it has been determined what policies should apply to the long-term management of radioactive waste, there will be a requirement to put them into effect. There are a number of organisations in existence, which might be responsible for implementation. Or new ones could be created.

6. Policy

Generating Public Debate

For illustrative purposes a programme of action is shown subject to amendment in the light of responses to this consultation. The dates suggested are dependent upon the level of research required following the end of Stage One. Consequently, they can only be rough guides as to when future stages might begin.

Regulation

• Under any regulatory system, storage will continue to be needed for radioactive wastes until a final management strategy is available.
• In the case of solid wastes with more than low levels of radioactivity, the implementation of a final management strategy is unlikely to be complete for several decades. Wastes requiring storage pending the development of a final management strategy will need to be maintained safely with minimal need for human intervention. Some wastes will need to be processed and packaged to achieve this.
• Over 99% of radioactive wastes are on sites licensed under the Nuclear Installations Act 1965 (nuclear licensed sites). The HSE regulates radioactive waste management on these sites.

• One view is that the arrangements described above are incomplete and may not be appropriate to today's needs.
• The agencies cannot directly require a site licensee to provide the information needed to judge the environmental impact of the storage and ultimate final management of waste. Nor can they set regulatory requirements. If the environment agencies were given a new statutory power over the storage of wastes, nuclear licensees would need to provide the relevant information to the agencies in order to obtain authorisations for storing wastes.
• The authorisation process would also give additional opportunities for consulting, and providing information to, the public.
• The alternative view is that there is no evidence that the current regime fails to provide effective regulation, nor that a statutory power for the agencies would enhance it.
• The existing arrangements provide positive advantages, including a robust and complete regime for the protection of workers, the public and the environment.
• They also ensure that the agencies are fully involved in matters affecting radioactive waste management, and full consultation by HSE on regulation of radioactive waste storage will provide sufficient opportunity for the views of the public to be taken into account.

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